England’s draft policy for data centres: why people in Wales should respond

Why people in Wales should respond

Planning is devolved, so this policy will not decide applications in Wales. It still matters here, for three reasons.

• It is likely to set the benchmark. Wales has no data-centre policy of its own. When the Senedd and the Welsh Government come to write one, what has been accepted in England will be the obvious starting point. The UK Government itself says the policy may be a “material consideration” in Wales.^[2]
• The power side is decided at UK level. Grid connections are reserved to Westminster, and the same tests (the “Data Centre Covenant”) are used to decide which data centres get priority for the grid. See what the Covenant means for Wales.
• Water and weather do not stop at the border. Several Welsh catchments supply England, and the same drought and heatwave questions arise on both sides.

Responding to an England-only consultation from Wales is entirely proper: the consultation is open to “any individual or organisation”.^[2] A short response from Wales also tells Ministers in both governments that people here are watching.

What the draft says

• Which projects: data centres with at least 100 MW of “rated IT load” are likely to be treated as nationally significant and decided by a Secretary of State rather than the local council (what “100 MW” means).
• A presumption of consent: if an applicant meets the requirements, “it is unlikely a DCO will be refused”. The stated exceptions are protected habitats, “human health and public safety, defence, irreplaceable habitats, or risk from flood or coastal erosion”, and the Green Belt (paragraphs 81 to 84).
• Five Covenant tests: lower electricity bills, investment in local communities (a “Local Benefit Plan”), environmental standards (protect nature, minimise water use, publish annual energy and water reports, reuse heat where practical), jobs and skills, and security. All data centres are “encouraged” to meet them; strategic data centres must meet them only “where they are seeking enhanced government support” (paragraph 59).
• Energy efficiency: the design must meet a Power Usage Effectiveness of 1.3 or better (paragraphs 140 and 148).
• Water: applicants should disclose their estimated annual and peak-day water use, consult water companies, and assess cumulative effects in the catchment (paragraphs 419 to 426).
• On-site power stations: only for “exceptionally strategic” projects, temporarily, until a grid connection is available (paragraph 159).

The same day the Minister for Water issued a statement for England asking operators, voluntarily, to publish their total and peak water use and their Water Usage Effectiveness, and noting that “Water companies do not have to supply data centres with water”. See water: what the three documents say together.

In a drought or a power shortage, who comes first?

We read the whole draft looking for anything that says households, or anyone else, would be put ahead of data centres when water or electricity is short. We found nothing. These are the passages that come closest:

Other rules point the other way. Data centres are Critical National Infrastructure so that they “can be supported by the government in the event of critical incidents” (paragraph 61). Under the separate electricity emergency code, data centres “vital to the operation of Essential Services” can apply to be protected from rota power cuts; households cannot.^[3] And the business water bans that water companies use in a drought list things like washing vehicles and watering plants, not cooling water.^[4]

Paragraph 417: what does “waterless” cooling mean?

Paragraph 417 says that modern data centres are “starting to use new technologies, such as closed ‘waterless’ cooling systems, which reduce the need for water during the cooling process, or eliminate the need altogether.” It is a description, not a requirement. Here is how the main cooling methods use water:

So when else is water used?

• On the hottest days. Many systems switch on water sprays at “peak heat, peak load, peak demand”,^[5] which is exactly when a drought or heatwave is under way. The Environment Agency’s analysis of metered water use at about 200 data centres is reported to show a clear summer peak, driven mainly by hybrid cooling.^[7]
• At the power station. Using less water on site usually means using more electricity, and generating electricity uses water. “There’s no such thing as a waterless data center — water use is water use.”^[5] In the US, the indirect water used for electricity and for making chips and servers can be twice the direct use.^[6]
• Everything else: filling and topping up closed loops, humidifying the server halls, staff facilities and construction.

Points to consider

These are our own reading of the draft, offered for you to weigh, not findings of any public body.

1. The summaries reassure more than the rules require. The foreword promises “robust assessment criteria”; the numbered paragraphs mostly say “should”, “encouraged”, “consider” and “have regard to”.
2. “Adhere to the highest environmental standards” turns out to mean “minimise water use” and publish reports. No water standard is set.
3. The five tests are said to “ensure” value to the UK (paragraph 79), but they are voluntary for every data centre except strategic ones seeking extra government support.
4. Drought is not a reason to refuse. Water scarcity is not among the exceptions to the presumption of consent.
5. A number for energy, none for water. There is a firm efficiency target (PUE 1.3) but no water target such as WUE. Because the cheapest way to improve energy efficiency is often to use water for cooling, a firm energy target with no water target could push designs towards using more water.
6. “Waterless” is in quotation marks for a reason. The phrase “during the cooling process” limits the claim to on-site cooling in normal weather. A closed loop still contains water, and the hottest days and the power station are left out.
7. The decisions that matter most may be made elsewhere. Priority for the grid will be decided under the Data Centre Covenant, by UK Ministers, for sites in Wales as well as England.
8. Critical National Infrastructure protects the data centre. Nothing in the draft protects households in the same way.

Points you may wish to make in your response

Use your own words; a few clear points carry more weight than a long letter. You might ask the Government to:

• state that, in a drought or an electricity supply emergency, supplies to households and essential public services come before data centres;
• add water scarcity and drought to the exceptions to the presumption of consent in paragraph 84;
• set a water standard (such as a maximum Water Usage Effectiveness) alongside the energy standard;
• require applicants to give their water use on the hottest day, not just an annual average, and the water used to generate their electricity;
• make annual publication of actual energy and water use a condition of consent, not just “an agreed plan”;
• make the Covenant tests requirements for every nationally significant data centre, not only for those seeking government support.
• publish the definition of a “strategic” data centre and the reasons for each decision of the Ministerial Control Centre, and consult the Welsh and Scottish Governments on any site in their countries.

Letters you could adapt

These are the questions we intend to put. You are welcome to adapt them.

Questions about a particular proposal near you should go to the planning authority for that application: see Start here.

Sources for this page

1. UK Government, Initial Proposal for a National Policy Statement for Data Centres (October 2026). Paragraph numbers on this page are the draft’s own. https://assets.publishing.service.gov.uk/media/6ae1c5937fe45a08a4036e4e/draft-national-policy-statement-for-data-centres.pdf
2. Department for Business, Innovation, Science and Trade, consultation page: ‘Draft National Policy Statement for Data Centres’ (closes 11:59pm on 8 January 2027). https://www.gov.uk/government/consultations/draft-national-policy-statement-for-data-centres
3. Department for Energy Security and Net Zero, Electricity Supply Emergency Code guidance (revised April 2026). https://assets.publishing.service.gov.uk/media/69d7b134ad08dc1bc975fa3b/esec-guidance-april-2026.pdf
4. South East Water, ‘Non-essential use ban: general questions’ (the business uses banned in a drought). https://www.business.southeastwater.co.uk/about-us/non-essential-use-ban-faqs/
5. Heapy P., ‘Beyond Binary: Data Center Water Use Isn’t All Or Nothing’, Facility Executive, 29 June 2026. https://facilityexecutive.com/beyond-binary-data-center-water-use-isnt-all-or-nothing/
6. Katanich D., ‘Can tech giants curb AI data centres’ growing thirst for water?’, Euronews, 7 September 2026. https://www.euronews.com/2026/09/07/tech-giants-claim-they-can-curb-ai-data-centres-thirst-for-water
7. Alexander A., ‘Data centres cooling drives heatwave demand’, The Ecologist, 1 July 2026 (reporting Environment Agency analysis of metered water use at about 200 data centres). https://theecologist.org/2026/jul/01/data-centres-cooling-drives-heatwave-demand